blagojevich defense filing

8/9/2019 Blagojevich defense filing

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IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONUNITED STATES OF AMERICA )

)v. ) 08CR888)) Judge James B. ZagelROD BLAGOJEVICH )MOTION FOR THE COURT TO ISSUE A TRIAL SUBPOENA TOPRESIDENT BARACK OBAMANow Comes Defendant Rod Blagojevich, by and through his counsels and herebyrequests this court issue a subpoena ad testificandum for President Barack Obama. Insupport ofsaid motion, defendant states the following:1

1. President Barack Obama was elected November 4, 2008 and was inauguratedJanuary20, 2009. Before being elected President, Mr. Obama was a United States Senatorfrom Illinois.2. As a result of the election of Mr. Obama, his Senate seat was open for appointmentbyGovernor Rod Blagojevich.3. The charges against Mr. Blagojevich stem from his appointment of President-electObamas vacated Senate seat.4. According to media reports, President Obama was interviewed by two United Statesattorneys and two FBI agents for two hours.21Although it is the defenses position that all tapes and sealed information be made public, to comply with

theProtective Order of April 14, 2009, portions that contain sealed information provided by the governmenthave beenredacted. The defense, however, urges this Court unseal the entire motion. See, this courts order dated

April 14,2010 (document 305) Redaction, in cases where the redacted words are relevant to the case andconsidered inreaching a decision, is still permitted but discouraged. See In re Krynicki, 983 F.2d 74, 75 (7th Cir. 1992)(Information that is used at trial or otherwise become the basis of decision enters the public record.)(citationomitted). The case for redaction has to be proven not presumed. ... But it is clear that the remedy to theobjectionthat a portion of a statement may be misleading to the public (and the jury pool) is not redaction but

disclosure of theomitted portion. Disclosure of written material a month and a half before the beginning of trial does notcome closeto presenting a significant threat that a fair jury cannot be found. The experience of the courts in caseswhich attractsignificant news coverage has shown that pretrial news reporting is an overstated menace to fair jurytrials.2 Barack Obama questioned by FBI agents over Blagojevich Illinois senate seat scandal, Toby Harnden,The


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Telegraph, December 26, 2008.

Case 1:08-cr-00888 Document 327 Filed 04/22/10 Page 1 of 112

5. On December 19, 2009, the defense filed a Motion for Discovery. In that motion, thedefense requested all notes, transcripts, and reports generated from the governmentsinterview of President Barack Obama.6. As of todays date, the defense has not received any notes, transcripts, or reportsfromPresident Obamas interview with the government.7. The government alleges that Defendant Rod Blagojevich met with a labor unionofficial who he believed to be in contact with the President-elect in regard to thevacant Senate seat, and suggested to the labor union official that Rod Blagojevichwould appoint Senate Candidate B to the vacant Senate seat in exchange for RodBlagojevich being named Secretary of Health and Human Services. (Indictment p.101, para. 10(c)).8. President Obama has stated publicly that he was confident that no representativesofmine would have any part of any deals3 related to this seat.49. Yet, despite President Obama stating that no representatives of his had any part ofany deals, labor union president told the FBI and the United States Attorneys that hespoke to labor union official on November 3, 2008 who received a phone messagefrom Obama that evening. After labor union official listened to the messagelabor union official told labor union president Im the one. Labor unionpresident took that to mean that labor union official was to be the one to deliverthe message on behalf of Obama that Senate Candidate B was his pick. (Laborunion president 302, February 2, 2009, p. 7).10. Labor union official told the FBI and the United States Attorneys Obamaexpressed

his belief that [Senate Candidate B] would be a good Senator for the people ofIllinois and would be a candidate who could win re-election. [Labor unionofficial] advised Obama that [labor union official] would reach out to GovernorBlagojevich and advocate for [Senate Candidate B].. . . [Labor union official]called [labor union president] and told [labor union president] that Obama wasaware that [labor union official] would be reaching out to Blagojevich. (Laborunion official 302, February 3, 2009 p. 3).3 Deal is defined as a transaction; bargain; contract; an arrangement for mutual advantage. Merriam-WebsterOnline Dictionary. A deal requires two willing participants.4 President-elect Barack Obama press conference, December 11, 2008.

Case 1:08-cr-00888 Document 327 Filed 04/22/10 Page 2 of 11311. According to Senate Candidate B, on November, 4 2008, Senate Candidate Bspoke with labor union official about the Senate seat. Labor union official saidhe spoke to Obama. Labor union official said he was going to meet withBlagojevich and said he was going to push Blagojevich hard on this. Accordingto Senate Candidate B, labor union officials language could have been strongerthan the language that she was reporting to the government. (Senate Candidate


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B 302, December 19, 2008).12. On November 5, 2008, Blagojevich told John Harris that labor union official talkedto Barack Obama, wants to come and see me. Blagojevich then told Harris thatlabor union official was very explicit with me, I talked to Barack about theSenate seat. Can I come and see ya? Can I do it tomorrow? I said, sure.

(Blagojevich Home Phone Call # 261).13. A supporter of Presidential Candidate Obama suggested that she talk to the wifeofGovernor Blagojevich about Senate Candidate B for Senator. (Valerie Jarrett302, December 19, 2008). Supporter of Presidential Candidate Obama ismentioned in a phone call on November 3, 2008, having offered fundraising inexchange for Senate Candidate B for senator (Blagojevich Home Phone Call #149).14. President Obama has direct knowledge to allegations made in the indictment. Inaddition, President Obamas public statements contradict other witness statements,specifically those made by labor union official and Senate Candidate B. It is

anticipated that labor union official will be a witness for the government. Hisaccounts of events directly related to the charges in the indictment are contradicted byPresident Obamas public statement.15. Even the prosecutor in this case indicated theres no allegation that thepresidentelect

theres no reference in the complaint to any conversations involving presidentelector indicating that the president-elect was aware of it.516. There are two conflicting stories and the defense has the right to admit evidencethatcontradicts the governments claims. Only President Obama can do this.17. President-elect Obama also spoke to Governor Blagojevich on December 1,2008in Philadelphia. On Harris Cell Phone Call # 139, John Harris and Governorslegal counsel discuss a conversation Blagojevich had with President-elect5

Fitzgerald Press Conference on Blagojevich. Transcript. Chicago Sun Times, Lynn Sweet, December 9,2008.


Obama. The government claims a conspiracy existed from October 22, 2008continuing through December 9, 2008.6That conversation is relevant to the defenseof the governments theory of an ongoing conspiracy. Only Rod Blagojevich andPresident Obama can testify to the contents of that conversation. The defense is

allowed to present evidence that corroborates the defendants testimony.718. President-elect Obama also suggested Senate Candidate A to GovernorBlagojevich.John Harris told the FBI and the United States Attorneys that he spoke toPresidents Chief of Staff on November 12, 2008. Harris took notes of theconversation and wrote that Presidents Chief had previously worked asBlagojevich's press secretary. Obama agreed of Staff told Harris that SenateCandidate A was acceptable to Obama as a senate pick. (Harris handwritten


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notes, OOG1004463) Presidents Chief of Staff told the FBI that he could notsay where but somewhere it was communicated to him that Senate Candidate Awas a suggested candidate viewed as one of the four right candidates by theObama transition team. (Rahm Emanuel 302, p. 5, December 20, 2008). Harristold Blagojevich Obamas suggestion on November 12, 2008 (Blagojevich Home

Phone Call # 539).19. President-elect Obama was also involved in other senate candidate choices. OnDecember 8, 2008, John Harris secretarys call log noted Presidents Chief ofStaff called at 10:47 am and wrote needs to talk to you asap (Harris 302,February 20, 2009). Presidents Chief of Staff told the FBI that he had aconversation discussing the Senate seat with Obama on December 7, 2008 inObamas car. Presidents Chief of Staff told the FBI Obama expressed concernabout Senate Candidate D being appointed as Senator. [Presidents Chief ofStaff] suggested they might need an expanded list to possibly include names ofAfrican Americans that came out of the business world. [Presidents Chief ofStaff] thought he suggested Senate Candidate E who was the head of the Urban6 See, Paragraph 38, Indictment entitled Efforts to Obtain Personal Financial Benefits for RODBLAGOJEVICH inReturn for his Appointment of a United States Senator. The paragraph states: Beginning in or aboutOctober2008, and continuing until on or about December 9, 2008 . . .7 See, Wisconsin ex rel.Monsoor v. Gagnan, 497 F.2d 1126 (7th Cir. 1974) (holding that the state trialcourtcommitted reversible error and violated the defendants Sixth Amendment right to a fair trial andcompulsoryprocess by striking the testimony of the only corroborating witness to a phone call that related directly tothedefendants defense), citing Braswell v.Wainwright, 463 F.2d 1148, 1155-56 (5th Cir. 1972) (holding thatCloselyrelated to [the defendants] Sixth Amendment right is his right to a fair trial - - to due process. [The

defendant] had aright to at least present the testimony of his sole corroborating witness to the jury. That the jury might stillhavereturned a guilty verdict is beside the point; judgment of the credibility of witnesses is for the trier of fact.)


League and with Presidents Chief of Staffs suggestion." (Presidents Chief ofStaff, 302, 12-20-08).20. President Barack Obama has direct knowledge of the Senate seat allegation.President Obamas testimony is relevant to three fundamental issues of thatallegation. First, President Obama contradicts the testimony of an importantgovernment witness. Second, President Obamas testimony is relevant to thenecessary element of intent of the defendant. Third, President Obama is the only onewho can say if emissaries were sent on his behalf, who those emissaries were, andwhat, if anything, those emissaries were instructed to do on his behalf. All of theseissues are relevant and necessary for the defense of Rod Blagojevich.21. Tony Rezko is one of the governments main witnesses.8 Mr. Rezkos credibility isextremely relevant in this trial. In many instances, Mr. Rezko is the governmentscrucial witness to prove up their allegations.9 Mr. Rezko wrote a letter to a federal


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judge stating the prosecutors have been overzealous in pursuing a crime that neverhappened. They are pressuring me to tell them the wrong things that I supposedlyknow about Governor Blagojevich and Senator Obama. I have never been a party toany wrongdoing that involved the Governor or the Senator. I will never fabricate liesabout anyone else for selfish purposes. (Exhibit A)

22. However, the defense has a good faith belief that Mr. Rezko, President Obamasformer friend, fund-raiser, and neighbor told the FBI and the United States Attorneysa different story about President Obama. In a recent in camera proceeding, thegovernment tendered a three paragraph letter indicating that Rezko has statedin interviews with the government that he engaged in election law violations bypersonally contributing a large sum of cash to the campaign of a public officialwho is not Rod Blagojevich. Further, the public official denies being aware ofcash contributions to his campaign by Rezko or others and denies havingconversations with Rezko related to cash contributions. Rezko has also statedin interviews with the government that he believed he transmitted a quid pro quooffer from a lobbyist to the public official, whereby the lobbyist would hold a

fundraiser for the official in exchange for favorable official action, but that the8 The defense has requested that the government provide a witness list. To date, the government has notprovided alist of witnesses.9 See, Counts 1, 2, and 3 of the Indictment. The Pension Obligation Bond Deal ( p. 9 (para. 7), p. 48(para. 6)); TheSolicitation of Ali Ata (p. 9 (para. 9)), Benefits Given to Rod Blagojevich (Rezko directed or providedpayments toRod Blagojevichs wife) (p. 53 (para. 9 (a.), (b.), (c.))), Blagojevich used the power of the Office of theGovernor togive Rezko substantial influence over appointments to boards and commissions (p. 8 (para. 5)) (p. 13(para. 18)) (p.42 (para. 4-5)) (p. 47 (para. 4)) (p. 53 (para. 17)).


public official rejected the offer. The public official denies any suchconversation. In addition, Rezko has stated to the government that he and thepublic official had certain conversations about gaming legislation andadministration, which the public official denies having had.1023. President Obama is the only one who can testify as to the veracity of Mr. Rezkosallegations above.24. President Obama has pertinent information as to the character of Mr. Rezko.President Obama can testify to Mr. Rezkos reputation for truthfulness as well as hisown opinion of Mr. Rezkos character. See, Fed. R. Evid. 405(a) and 608. Mr.Rezko and President Obama became friends in 1990. According to President Obama,Mr. Rezko raised as much as $60,000 in campaign contributions for Obama.1125. Based on the relationship that President Obama and Mr. Rezko had, PresidentObamacan provide important information as to Mr. Rezkos plan, intent, opportunity, habitand modus operandi. See, Fed. R. Evid. 404(b) and 406. For example, in June 2005,President Obama purchased a house for $1.65 million, $300,000 below the askingprice. On the same day Tony Rezkos wife, Rita, paid full price -- $625,000 -- for the


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adjoining land. In January 2006, Obama paid Mr. Rezko $104,500 for a strip of theadjoining land. The transaction took place when it was widely known that Mr. Rezkowas under investigation.12 President Obamas relationship with Tony Rezko isrelevant and necessary Fed. R. Evid. 404(b) and 406 evidence.26. Regarding a Presidential subpoena, the Supreme Court has held that:

The right to the production of all evidence at a criminal trial . . . hasconstitutional dimensions. The Sixth Amendment explicitly confers upon10The defense has a good faith belief that this public official is Barack Obama.See, Obama onRezko deal: Itwas a mistake, Dave McKinney, Chris Fusco, and Mark Brown, Chicago Sun Times, November 5, 2006.SenatorBarack Obama was asked: Did Rezko or his companies ever solicit your support on any matter involvingstate orfederal government? Did Al Johnson, who was trying to get a casino license along with Tony Rezko, orRezkohimself ever discuss casino matters with you? Senator Obama answered: No, I have never been askedto doanything to advance his business interest. In 1999, when I was a State Senator, I opposed legislation to

bring acasino to Rosemont and allow casino gambling at docked riverboats which news reports said Al Johnsonand TonyRezko were interested in being part of. I never discussed a casino license with either of them. I was avocalopponent of the legislation. Obamas involvement with Tony Rezko and this legislation coincideswith thethree paragraph summary the government has provided to the defense referenced above.11

Obama on Rezko deal: It was a mistake, Dave McKinney, Chris Fusco, and Mark Brown, Chicago SunTimes,November 5, 2006.12

8 Things you need to know about Obama and Rezko, Tim Novak, Chicago Sun Times, January 24,

2008.Case 1:08-cr-00888 Document 327 Filed 04/22/10 Page 6 of 117

every defendant in a criminal trial the right to be confronted with thewitnesses against him and to have compulsory process for obtainingwitnesses in his favor. Moreover, the Fifth Amendment also guarantees thatno person shall be deprived of liberty without due process of law. It is themanifest duty of the courts to vindicate those guarantees, and to accomplishthat it is essential that all relevant and admissible evidence be produced.United States v. Nixon, 418 US 683, 711 (1974).27. Although it is not commonplace to subpoena a sitting President, the Supreme Court

has noted that sitting Presidents have been subpoenaed by federal courts withsufficient frequency that such interactions between the Judicial and Executivebranches can scarcely be thought a novelty. Clinton v. Jones, 520 US 681, 704, 137L.Ed. 2d 945, 967 (1997).28. Indeed, history is replete with cases in which Presidents have been subpoenaed orhave provided evidence in federal cases.1329. In addition to criminal trials, Theodore Roosevelt, Harry Truman and John F.Kennedy were defendants in civil cases involving actions prior to taking office.


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Clinton v. Jones, 520 US at 692, citing People ex rel. Hurley v. Roosevelt, 179 N.Y.544, 71 N.E. 1137 (1904); DeVault v. Truman, 354 Mo. 1193, 194 S.W.2d 29 (1946);Bailey v. Kennedy, No. 757,200 (Cal. Super. Ct. 1960); Hills v. Kennedy, No. 757,201(Cal. Super. Ct. 1960). President Nixon was deposed in several civil actions and13 See, United States v. Burr, 25 F. Cas. 30 (No. 14,692d) (CC Va. 1807) (President Thomas Jeffersonordered to

comply with a subpoena duces tecum in the trial of Aaron Burr); Rotunda, Presidents and Ex-PresidentsasWitnesses: A Brief Historical Footnote, 1975 U. Ill. L. F. 1, 5-6 (referencing President Monroes answerstointerrogatories in the trial of an appointee, whose meetings with the President were cited as contributingfactors toaccusations he received his job appointment under intrigue and misconduct and also references alengthydeposition given by President Grant in a criminal case); United States v. Nixon, 418 US 683, 41 L.Ed. 2d1039(1974) (The Supreme Court held that President Nixon was obligated to comply with a subpoena ducestecum in acriminal trial); United States v. Poindexter, 732 F. Supp. 142, 145, citing to United States v.Mitchell, 385

F.Supp1190 (D.D.C. 1974) and United States v. Haldeman, 559 F.Supp.2d 31, 80-81 (D.C. Cir. 1976) (wherePresidentNixon was subpoenaed by the Government and defendants in criminal trials of his appointees resultingfrom theWatergate scandal); United States v. Fromme, 405 F.Supp. 578 (ED Cal. 1975) (where President Fordwassubpoenaed and deposed as a defense witness in the criminal trial of the woman accused of attemptingto assassinatehim); United States v. Poindexter, 732 F.Supp. at 145 (D.D.C. 1990) (referring to President Cartersvideotapeddeposition in a criminal trial and a separate grand jury investigation); Id., at 144-46, 159-60 (wherePresident

Reagan was ordered to testify via videotaped deposition in the criminal trial resulting from the Iran-Contraaffair);and Clinton v. Jones, 520 US at 705, citing United States v.McDougal, 934 F. Supp. 296 (ED Ark. 1996)andUnited States v. Branscum, No. LRP-CR-96-49 (ED Ark., June 7, 1996) (referencing President Clintonscompelledtestimony via videotaped deposition in two criminal proceedings, including as an impeachment witness forthedefense in the McDougalcase).


Presidents Lincoln, T. Roosevelt, Tyler and Adams were compelled to appear beforecongressional committees. United States v. Poindexter, 732 F. Supp at 145.

30. It is well settled that the Federal Courts have subpoena power over a sittingPresident. Chief Justice Marshalls early opinion from the Burrcase hasbeen unequivocally and emphatically endorsed by the Supreme Court andother federal courts. See, United States v. Nixon, 418 US at 706; Clinton v.Jones, 520 US at 704.Whatever difference may exist with respect to the power to compel thesame obedience to the process, as if it had been directed to a privatecitizen, there exists no difference with respect to the right to obtain it. ...


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The guard, furnished to this high officer, to protect him from beingharassed by vexatious and unnecessary subpoenas, is to be looked for inthe conduct of a court after those subpoenas have issued; not in anycircumstance which is to precede their being issued. United States v.Fromme, 405 F. Supp. At 582, citing United States v. Burr, at p.30.

31. The Supreme Court has consistently ruled that the twofold aim [of criminal justice]is that guilt shall not escape or innocence suffer. United States v. Nixon, supra, citingBerger v. United States, 295 US 78, 88 (1935). The Court continued, in Nixon, thatthe need to develop all relevant facts in the adversary system is both fundamentaland comprehensive. The ends of criminal justice would be defeated if judgments wereto be founded on a partial or speculative presentation of the facts. . . To ensure that

justice is done, it is imperative to the function of courts that compulsory process beavailable for the production of evidence needed either by the prosecution or by thedefense. United States v. Nixon, 418 US at 709. In sum,[Federal precedent holds that] no person, even a President, is above thelaw and that in appropriate judicial proceedings, documents and other

tangible evidence within the very office of the President may be obtainedfor use in those judicial proceedings. Similarly, where the Presidenthimself is a percipient witness to an alleged criminal act, the Presidentmust be amenable to subpoena as any other person would be . UnitedStates v. Fromme,405 F.Supp. at 582 (emphasis added).32. Here, President Obama is a critical witness. All of President Obamas testimonywould entail evidence he witnessed before he became president and does not involveExecutive Privilege. As the District Court ruled in Fromme:Case 1:08-cr-00888 Document 327 Filed 04/22/10 Page 8 of 119

Notwithstanding the burden which is imposed on the person of thePresident if he is called to testify as a witness in a criminal trial, thiscourt has an even heavier burden to ensure a fair and a speedy trial tothe accused, with total regard for all the rights and protections affordedan accused under the law of this land.[The] allowance of the [Executive] privilege to withhold evidence thatis demonstrably relevant in a criminal trial would cut deeply into theguarantee of due process of law and gravely impair the basic function ofthe courts. United States v. Fromme, 405 F.Supp. at 583 (emphasisadded)(citations omitted), citing United States v. Nixon, 418 US at 712.33. President Obama has direct and intimate knowledge of facts alleged in theindictment.Indeed, the President is a percipient witness. United States v. Fromme, 405 F.Supp.at 581. President Obama is a witness to the conduct alleged as well as animpeachment witness to at least two of the governments critical witnesses.1434. The defense does not take lightly the overwhelming schedule the President has andthe security constraints surrounding his testimony. A videotape deposition willremedy both of those legitimate concerns. See, Fed. R. Crim. Pro. 15 and see also,United States v. Fromme, 405 F.Supp. at 582 (videotape deposition protect[s] theaccuseds rights under the Sixth Amendment of the United States Constitution while


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at the same time imposing the least onerous burden on the person and the office of thePresident of the United States.).35. The defense requests that, if this court grants a videotape deposition in lieu of in-courttestimony, defense counsel be permitted to conduct the examination of President

Obama after the governments case in chief. See,U

nited States v.M

cDougal, 103F.3d 651 (ED Ark. 1996) and 943 F.Supp. 296 (ED Ark. 1996) (videotapeddeposition of President Clinton which took place at the White House, and becausePresident Clinton was called as a defense witness to impeach David Hale, the Courtordered that President Clinton not testify until after the in-court testimony of DavidHale.).36. The defendant has a right to put on a case and challenge the allegations thegovernment attempts to prove. President Obama is relevant and necessary to the14 Joseph Aramanda is another government witness that President Obama can testify to as well. Joseph

Aramandasson, John Aramanda, received an internship with then-Senator Obama. Joseph Aramanda contributed$11,500 to

Obama since 2000 and John Aramanda was recommended by Tony Rezko. Internship also links Obama,Rezko,Frank Main, Chicago Sun-Times, December 24, 2006. President Obama will be able to provide relevantinformationas to Joseph Aramanda. See, para. 24 and 25, supra.


defendants case. The defense understands that the President of the United States ofAmerica is not a routine witness and would not request his appearance if it did notthink he was critical to the liberty of Rod Blagojevich. Whatever security orscheduling concerns can be reduced by arranging for the most convenientpresentation of testimony. The President can testify via video conference or can be

deposed outside of court at an evidence deposition. These options would satisfy thedefendants fundamental right to a fair trial and security and scheduling concerns.37. The defense requests this court grant this motion not because Rod Blagojevich wasthe Governor of Illinois, but because he is a defendant in a criminal case where hisliberty and freedom are at stake. Likewise, the defense requests this court grant thismotion to issue a subpoena ad testificandum to President Obama, not because he isthe President of the United States, but rather because he is a witness necessary to RodBlagojevichs Constitutional right to a fair trial. Justice requires no more and no less.it would be inconceivable -- in a Republic that subscribes neither to theancient doctrine of the divine right of kings nor to the more modernconceit of dictators that they are not accountable to the people whom

they claim to represent or to their courts of law -- to exempt [thePresident] from the duty of every citizen to give evidence that willpermit the reaching of a just outcome of this criminal prosecution.Defendant has shown that the evidence of the . . . President is needed toprotect his right to a fair trial, and he will be given the opportunity tosecure that evidence. United States v. Poindexter, 732 F. Supp at 159.WHEREFORE, defendant Rod Blagojevich respectfully requests this Honorable Court


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order the government turn over to the defense any and all reports generated during anyand allinterviews had with President Barack Obama and issue a subpoena ad testificandum forPresident Obama to appear at the trial of United States v. Rod Blagojevich.Respectfully submitted,

/s/ Sam AdamSheldon SoroskySam AdamMichael GillespieSamuel E. AdamAaron GoldsteinLauren Kaeseberg6133 S. EllisChicago, IL 60637(773) 752-6950

Attorneys for Rod Blagojevich, DefendantCase 1:08-cr-00888 Document 327 Filed 04/22/10 Page 10 of 1111

CERTIFICATE OF SERVICEThe undersigned hereby certifies that Defendants MOTION FOR THE COURT TOISSUE A TRIAL SUBPOENA TO PRESIDENT BARACK OBAMA was served on April22,2010, in accordance with Fed. R. Crim. P. 49, Fed. R. Civ. P. LR 5.5, and the GeneralOrder onElectronic Case Filing (ECF) pursuant to the district courts system as to ECF filers./s/ Sam AdamOne of the attorneys for Rod BlagojevichCase 1:08-cr-00888 Document 327 Filed 04/22/10 Page 11 of 11

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